Dow does not admit or deny allegations in the matter, said spokesperson Rebecca Bentley.

"Dow cooperated with the SEC throughout this process and, while the company could have continued with the matter, has chosen to settle to achieve finality and bring clarity to future disclosure decisions," Bentley said. "The expenses at issue were legitimate business expenses authorized by Dow and within the scope of executive job duties. This matter was not about whether the expenses should have been incurred, but only how they were classified for disclosure purposes."

The undisclosed perks included personal use of the Dow aircraft, according to the SEC order.

Dow also agreed to hire an independent consultant as part of the settlement to evaluate and recommend changes to how the company discloses perks.

"We have already begun implementing changes to improve perquisite disclosure based on this settlement, and we look forward to working with the independent consultant to further improve the evaluation and disclosure of perquisites in future years," Bentley said.

When asked if an independent consultant had been hired yet, Bentley said she is not in a position to share any further.